Re Bill 4, Cap and Trade…

ERO number

013-3738

Comment ID

10242

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Individual

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Comment

Re Bill 4, Cap and Trade Cancellation Act, 2018:

1. The most recent report from the IPCC emphasizes the urgency for all peoples, worldwide, to reduce emissions of GreenHouse Gases (GHGs). Hence, it is irresponsible for the new government in Ontario to abruptly cancel the existing Cap and Trade program, before having a replacement program in place. Any such replacement program must be designed to enable Ontario residents and Ontario industries to reduce their proportional share of GHGs, in order to meet the Canadian federal government's already declared reduction targets under the United Nations Paris Agreement of 2015.

By "enable Ontario residents" (above), I mean that residents and industries must still be able to reduce their GHGs at equal or lower cost, compared to the existing Cap and Trade program, which currently provides funding to assist people to meet the declared targets.

2. The proposed cancellation will be harmful to Ontario businesses who had conscientiously committed themselves to reduce GHGs from their business operations. The new Ontario government has made a big deal about how it is here to help businesses; but in reality, by abruptly cancelling an existing program, your are undermining your own efforts. Businesses need certainty, continuity and trust. Any program to create incentives to industry to change their operations must ensure many years of continuity. To abruptly stop such a program is clearly irresponsible from the perspective of the ultimate goal (to reduce GHGs). It is also irresponsible because of the lack of trust that is created in the business community. Businesses will be reluctant, even fearful, of working with any other Ontario Government program in the future.

3. If an equivalent or more effective program is not first introduced, then cancelling this specific Cap and Trade program is irresponsible towards all people, worldwide, who will be harmed by more air pollution and by higher emissions of GHGs for many years into the future. (The IPCC lays out all of the potential harms in their many reports, including the latest report.) Such behaviour would thus harm the reputation of Ontario and Canada in the eyes of the rest of the world. Most other governments are taking seriously their environmental commitments made in Paris, 2015.

4. The very concept of the Cap and Trade program requires that it remain in place for many years, if it is to be effective. Thus, such programs need to be protected from the whims of electoral politics, to be effective. Ontario should follow the lead of other countries like the U.K. in making an emission-reduction program more permanent. That is, not subject to every change in electoral politics; but rather given all-party support when it is established. This is a suggestion made by Ontario's own Environmental Commissioner.

5. The new government cannot assume that their recent electoral success was some sort of referendum on carbon pricing policies, since referendums are determined by the popular vote: only 40 % means you lost. The majority in Ontario understand the need to protect our natural environment; and thus most people understand the need for our energy systems to transition to become carbon-free. What most people want, however, is financial assistance from the government, in order to make such a big change in both personal and public infrastructure. The Cap and Trade program was doing this. It should not be stopped so prematurely and so abruptly.

6. Finally, I would like to endorse the most recent report from the Environmental Commissioner of Ontario: Climate Action in Ontario: What’s Next: 2018 Greenhouse Gas Progress Report. This says clearly what a responsible government would do.